20030313Supplemental Comments.pdf

Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
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UTILI r It;) CC,i-\t'\\SSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF P ACIFICORP DBA UTAH POWER &
LIGHT COMPANY FOR APPROVAL OF
AMENDED ELECTRIC SERVICE SCHEDULE)
72-IRRIGATION LOAD CONTROL CREDIT)RIDER PROGRAM
Case No. PAC-O3-
IDAHO IRRIGATION
PUMPERSASSOCIATION
INC'S SUPPLEMENTAL
COMMENTS
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), through
undersigned counsel, and hereby respectfully submits its supplemental comments on
PacifiCorp s proposed IrrigationLoad Control Credit Rider Program.
Following the decision meeting on March 10, 2003 , representatives from
PacifiCorp and the Irrigators have been able to discuss alternative methodologies for determining
the curtailment credit for the 2003 irrigations season. Our discussions focused on a methodology
that looked at the value of the credit based on the shifting by the irrigators of the curtailed load
from super-peak to off-peak hours. Although the discussion was constructive, the parties were
unable to agree on a specific methodology.
PacifiCorp has proposed a credit based on the difference between the market
prices for during super-peak and light-load hours. This credit is then discounted by 70% to
account for uncertainties, such as whether the curtailed load will actually shift. The revised
monthly credits result in increases of up to 29% over the monthly credits initially proposed.
IRRIGATORS' SUPPLEMENT TO COMMENTS RE: ELECTRIC SERVICE SCHEDULE 72 -
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The Irrigators believe that the appropriate scenario to be used is the one that assumes
that the shift in curtailed load will occur from super-peak to off-peak hours. The shoulder or light-
load hours are already just too full to have any usage shifted to this time frame. PacifiCorp s use of
a 70% discount to us is no more than a simple discounting of the value of the interruption. Some
minimal level of discounting may be appropriate if the irrigators were not going to move their usage
to a different timeframe. However, due to the irrigators ' need to water their crops and thus shift
usage (because PacifiCorp has designed the program so the participants will get interrupted), there is
a very high confidence level that PacifiCorp will get all of its energy and demand revenues as if
there were no interruptions. These revenues would already include the cost of electricity priced at
the system average cost. PacifiCorp s methodology also further discounts the interruption credit by
assuming that the Irrigator must also pay an additional amount for off-peak or light-load power when
the average cost of power, i., the $43.58 per MWh, is built into the rates that will be paid by the
irrigators because the usage will shift. As such, it totally does not get around the "lost revenue
issue that was correctly raised by Commission Staff. The Irrigators believe that the most appropriate
way to value the interruptibility credit is the methodology proposed by Commission Staff.
Notwithstanding, one point that the parties do agree on is the need for a timely load
control program for the 2003 irrigation season. Therefore, the Irrigators would propose an
alternative to PacifiCorp s proposal. Since we do not have access PacifiCorp s model to plug in
what we believe to be the appropriate numbers, we did some simple scaling. Because the kilowatt
credits that PacifiCorp proposed reflected a discount, we simply took these credits and divided by
70% in order to come up with a proposed monthly credit, as follows:
June
July
Aug.
$2.20/ kW-mo
$2.94/ KW-mo
$3.21 / kW-mo
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S POST-HEARING BRIEF - 2
Sept. $1.80/ kW-mo
These values represent an increase in PacifiCorp s credit of approximately 42% across the board.
Further, because we believe the curtailed load will be shifted to off-peak hours, these values
still allow the PacifiCorp to collect the full $43.58 per MWh of revenue for essentially all energy
that was interrupted. We believe that the credit should not include both the recovery of the off-peak
cost of this shifted energy and the revenue from the shifted energy. The Irrigators' proposal for the
2003 irrigation season allows PacifiCorp to have both.
The Irrigators do agree with PacifiCorp s proposal that the credit for interruptibility
should be evaluated further after the 2003 irrigation season to determine the extent of load shifting
and to finalize a methodology to be used in valuing the same. This should be done early in the fall
of 2003 so that the matter can be timely addressed by the Commission Staff, the Irrigators and
PacifiCorp.
Respectfully submitted this 13th day of March, 2003.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
/~~
Attorneys for the Idaho Irrigation Pumpers
Association, Inc.
IRRIGATORS' SUPPLEMENT TO COMMENTS RE: ELECTRIC SERVICE SCHEDULE 72 -
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this l~~day of March, 2003, I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Supplemental Comments Re:
PacifiCorp s Irrigation Load Control Credit Rider to each of the following, via U.S. Mail, e-mail
or hand delivery:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
E-mail: jjewell(fYpuc.state.id.
Hand Delivery/E-mail
Doug Larson
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
Soda Springs, Idaho 83276
S. Mail
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, Idaho 83720-0074 Via Facsimile/E-mail
Mary S. Hobson
Stoel Rives, LLP
101 S. Capital, Suite 1900
Boise, Idaho 83702-5958 Via Facsimile
John M. Eriksson
Stoel Rives, LLP
201 South Main Street, #1100
Salt Lake City, Utah 84111-4904 Via Facsimile/e-mail
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ERIC L. OL
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S POST-HEARING BRIEF - 4